International Tax Blog

3 New IRS Practice Units

Yesterday the IRS published a new practice unit titled “IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII)”. In addition, Wednesday they published the practice unit “Revised ASC 730 Directive - Computing Qualified Research Expense”, and last week they published the practice unit "Foreign Tax Redeterminations". These 3 practice units have been added to our Practice Units By Topic page. Read more →

Form 8993 With Graphic of Formulas

Below is an image of Form 8993 with some sample numbers. The image shows the formulas used to calculate FDII, with color coding to show where the numbers on the form go in the formulas. Click here for a PDF version of the graphic. Read more →

GILTI Deduction Allowed With 962 Election (Proposed Regulations)

The IRS has issued proposed regulations on the GILTI deduction under Code §250. The proposed regulations indicate that a GILTI deduction will be available for an individual who makes a Code §962 election to be taxed at corporate rates. The preamble to the proposed regulations provides in part: Congress enacted section 962 to ensure that individuals’ tax burdens with respect to undistributed foreign earnings of their CFCs “will be no heavier than they would have... Read more →